The District of Columbia’s Retirement Board is invested in Iran through the state-owned, Putin-controlled Russian oil and natural gas company Gazprom, according to both local media reports and Gazprom itself.

The board, which is an independent agency responsible for managing the district’s $4.5 billion pension fund, has to comply with the “Prohibition of the Investment of Public Funds in Certain Companies Doing Business with the Government of Iran and Sudan Divestment Conformity Act of 2008.”

“It does not appear that the company [Gazprom] has material oil and gas operations in Iran and did not reveal any plans for new business activities,” wrote Joseph Bress, the DCRB’s chairman, wrote in a February 28, 2013 letter [pdf] to the board. “Therefore, it is being maintained in the portfolio for close monitoring.”

Apparently, that monitoring wasn’t close enough. Press reports before that letter and since show clearly that Gazprom is investing in Iran.

A February 15, 2013 article mentions business negotiations with Iran. “In 2008, Gazpromneft and the National Iranian Oil company signed a memorandum on the development of the Azar and Shangule fields located in the Anaran Exploration Block,” wrote Russia Beyond the Headlines. Though Gazprom said it was leaving Iran in 2011, there’s little evidence that it actually left.